EPA Lead Renovators Frequently Asked Questions

The new EPA rules state that any contractor participating on renovation projects on buildings or spaces that were built before 1978 must get certified or they will face fines of $37,500 per day that they are working in a qualified space. The cost of getting certified is literally less than 1 percent the cost of a one-day fine.

Yes. As a certified abatement supervisor, you will be required to take a half day (4-hour) 'refresher' course. This is also true for those who have completed the lead abatement worker, or any recognized 'Lead Safe Work Practices' courses, including the lead based paint maintenance training program 'Work Smart, Work Wet and Work Clean to Work Lead Safe,' prepared by NATA for EPA and HUD; 'The Remodelers and Renovators Lead Based Paint Training Program,' prepared by HUD and NARI; or other courses previously approved by HUD for this purpose after consultation with EPA.

There are 2 certification options from USEPA. Renovation Firm Certification is $300 and a combined Lead-based Paint Activities and Renovation Firm Certification is $550. There is no fee for individual certification; individuals are certified by the trainer, not the USEPA. Please note that EPA Firm Certification fees do not include any individual training fees.

In addition to obtaining a Renovation Firm License, firms performing renovations must ensure that: - All persons performing renovation activities are certified renovators or have received on-the-job training by a certified renovator; A certified renovator is assigned to each renovation performed by the firm; and - All renovations are performed in accordance with applicable work practice standards.

Firms were able to apply for firm certification beginning October 2009 and had to be certified by April 2010. After April 2010, all renovations must be performed by certified firms in accordance with the work practice standards and associated recordkeeping requirements. We suggest that you submit your Renovation Firm application to EPA at least 8 weeks in advance of the date you would need the certification to allow for ample processing time.

Firms will have to re-apply for re-certification every 5 years. To maintain individual certification, a person must go through an accredited refresher course every 5 years.

No, but the certified Renovator must give on the job training to other persons performing renovation activities and maintain records of this training. Remember that a certified Renovator must be assigned to each renovation project, so you will likely need more than one certified Renovator if you have multiple jobs going on simultaneously.

Yes, after the renovation is complete, the firm must clean the work area. The certified Renovator must verify the cleanliness of the work area using a procedure involving disposable cleaning cloths. However, you may request that a clearance be performed by a certified professional.

At this point, USEPA is the enforcing agency for most states. States and tribes may (in the future) become authorized to implement this rule. The rule contains procedures for the authorization of states, territories, and tribes to administer and enforce these standards and regulations in lieu of a federal program.

This FAQ guide was prepared pursuant to section 212 of SBREFA. EPA has tried to help explain in this guide what you must do to comply with the Toxic Substances Control Act (TSCA) and EPA's lead regulations. However, this guide has no legal effect and does not create any legal rights. Compliance with the procedures described in this guide does not establish compliance with the rule or establish a presumption or inference of compliance. The legal requirements that apply to renovation work are governed by EPA's 2008 Lead Rule, which governs if there is any inconsistency between the rule and the information in this guide.

No. If the surface to be painted is not disturbed by sanding, scraping, or other activities that may cause dust, the work is not considered renovation and EPA's lead program requirements do not apply. However, painting projects that involve surface preparation that disturbs paint, such as sanding and scraping, would be covered.

EPA's lead program rules apply only to renovations performed for compensation; therefore, if you work on your own home, the rules do not apply. EPA encourages homeowners to use lead-safe work practices, nonetheless, in order to protect themselves, their families, and the value of their homes.

YES. The receipt of rent payments or salaries derived from rent payments is considered compensation under EPA's lead program. Therefore, renovation activities performed by landlords or employees of landlords are covered.